Data Protection information of BayWa r.e. UK Limited

As of: May 2018

1. Who is responsible for data processing and whom can you contact? 2. Which data is processed and from which sources does it come from? 3. For what purposes and on what legal basis will the data be processed? 4. Processing of personal data for advertising purposes 5. Processing of creditworthiness information 6. Who receives my data? 7. How long is my data stored? 8. Processing of applicant data 9. Communication by email 10. What information is collected when you visit this website? 11. Is any personal data transferred to other countries? 12. What data protection rights do I have? 13. Am I obliged to provide data?

Protecting your personal data is a top priority for us. Accordingly, we at BayWa r.e. UK Limited (hereinafter referred to as "BayWa r.e.") solely process your personal data (hereinafter referred to as "data") on the basis of statutory provisions. In this data protection declaration, we aim to give you full details of how your data is processed in our company and the data protection claims and rights to which you are entitled in accordance with the European General Data Protection Regulation (EU GDPR).

2. Which data is processed and from which sources does it come from?

We process the data that we receive from you when commencing and maintaining business relations. We also process data that we have received legitimately from credit agencies, creditor protection associations, publicly accessible sources (e.g. business registers, registers of associations, land registers, media) and other companies with which we have long-term business relationships.

Other data that we have received from you in the course of our business relationship (e.g. in customer meetings),

Data that we generate ourselves from master/contact data and other data, e.g. through analyses of customer requirements and customer potential.

The documentation of your declaration of consent for the receipt of e.g. newsletters.

Image data from video monitoring systems

Photos taken at public events

3. For what purposes and on what legal basis will the data be processed?

We process your data in accordance with the provisions of the General Data Protection Regulation (GDPR) and the currently valid version of the Data Protection Act 2018:

to comply with (pre-)contractual obligations (Art 6 para. 1 letter b GDPR): Your data is processed for the sale and distribution of our goods and services and procurement and logistics purposes as well as for supplier and customer management and analysis. In particular, data is processed when commencing and maintaining business relations with you and executing contracts with you, for example in the following cases:

Creating and managing a customer account or a supplier account

Delivering orders

Managing customer cards

Participation in sweepstakes

Sending information, e.g. requesting a catalogue

to meet legal obligations (Art 6 Para. 1 letter c GDPR): Your data has to be processed for the purpose of meeting various legal obligations, including but not limited to anti-money laundering, fraud prevention and health and safety legislation, codes and regulations.

to protect legitimate interests (Art 6 Para. 1 letter f GDPR): With the aim of balancing interests in mind, data may be processed beyond the actual scope required to execute the contract in order to protect either our own legitimate interests or those of third parties. Data processing to protect legitimate interests may include the following cases, for example:

Consultation of and data exchange with credit agencies and creditor protection associations to determine creditworthiness data and to maintain a group-wide creditworthiness database to identify financial default risks for joint customers;

Advertising or marketing

Measures for business management and the further development of services and products;

Maintaining a group-wide customer database to improve customer service

With your consent (Art 6 Para 1 letter a GDPR): If you have given us consent to process your data, it will be processed in accordance with the purposes and to the extent agreed in the declaration of consent. Consent that has been granted, e.g. to receive our newsletter, can be revoked at any time with future effect. If you wish to do so, please contact the party named under no. 1.

4. Processing of personal data for advertising purposes

We also use your data to communicate with you about your orders, certain products or marketing campaigns and to recommend products or services that might be of interest to you. You can object to such use of your personal data for advertising purposes at any time, either collectively or for specific measures. BayWa r.e. does not levy any charge for indicating such objection. If you wish to do so, please contact the party named under no. 1.

Product recommendations by email Pursuant to the legal requirements of the Privacy and Electronic Communications Regulations, BayWa r.e. is entitled to use the email address you provided to us when ordering a product or service for the purpose of directly advertising its own similar goods or services. You will receive these product recommendations from us, regardless of whether or not you have subscribed to a newsletter.

If you no longer wish to receive product recommendations from us by e-mail, you can object to the use of your address for this purpose at any time without incurring any costs, other than the data transmission costs at your standard rate. If you wish to do so, please contact the party named under no. 1. Of course, every email always includes an unsubscribe link.

Newsletter We use the so-called double opt-in procedure for sending the newsletter, i.e. we will only email you our newsletter if you have expressly confirmed to us beforehand that we should activate the newsletter service. We will then send you a notification email and ask you to reconfirm that you would like to receive our newsletter by clicking on a link contained inside. If you subsequently decide you no longer wish to receive any newsletters from us, you can object to this at any time without incurring any costs, other than the data transmission costs at your standard rate. Written notification to the party named under no. 1 will suffice in this case. Of course, an unsubscribe link is also included with each newsletter.

5. Processing of creditworthiness information

BayWa r.e. may transfer your personal data to BayWa r.e.’s selected credit agencies to assess your creditworthiness in relation to your applications for, the implementation of and termination of business relationships with BayWa r.e., or in relation to fraudulent behaviour. The legal basis for these transfers is established by Articles 6(1)(b) and 6(1)(f) of the general Data Protection Regulation (GDPR). Transmissions based on Article 6 paragraph 1 letter f GDPR may only proceed when required to safeguard the legitimate interests of BayWa r.e. or third parties and when doing so does not outweigh the interests or fundamental rights and freedoms of the data subject which require protection of personal data to be upheld. BayWa r.e. shall notify you in advance of making such transfers and shall provide you with the details of the credit agencies being engaged.

Maintaining a group-wide credit rating database If we have obtained creditworthiness data about you within the legally permissible scope (e.g. from a credit agency), we store it in a system to which the Group companies participating in BayWa Credit Management have access. The aim is to facilitate transaction processing for joint customers and to identify financial default risks. The creditworthiness database is only accessed if there is a legitimate interest in the respective group company.

6. Who receives my data?

Even if we use a service provider in the context of order processing, we remain the party responsible for protecting your data. All contractors are contractually obliged to handle your data confidentially and process it only within the scope required for the provision of services. The contractors we commission will receive your data if required to perform their respective services. These include, for example, IT service providers that we need to operate and safeguard our IT system as well as advertising and address publishers for our own advertising campaigns.

Your data will be processed in customer databases of BayWa AG and its subsidiaries, including BayWa r.e. These customer databases support efforts to improve the level of existing customer data (duplicate cleanup, moved/dead indicators, address correction), and enable enrichment with data from public sources. This data is made available to the BayWa Group companies participating in the BayWa customer database (participating companies) and can be used for personalised direct marketing campaigns (e.g. newsletters), targeted online marketing and personalised online shop design.

Through the customer database, participating companies that serve the same customers should be able to use information about these customers across organisations. This approach aims to provide customers with the most up-to-date and relevant information at all times. This processing of customer interests constitutes profiling as defined by Art. 4 GDPR; but no automated decision-making takes place. Customer data is stored separately for each company, with BayWa AG acting as a service provider for the individual participating companies.

If an offer is made or sold via manufacturer portals, data you have provided will be processed directly in the manufacturer's portal.

If there is a legal obligation and in the context of legal proceedings, authorities and courts as well as external auditors may also receive your data.

In addition, insurance companies, banks, credit agencies and service providers may also receive your data for the purpose of entering into and fulfilling contracts.

7. How long is my data stored?

We process your data until the business relationship ends or where retention can be justified for statutory, regulatory, legal or social security reasons or until any legal disputes in which the data is required as evidence have ended.

For video monitoring, image data is usually deleted after 31 days.

8. Processing of applicant data

If you send us your application via the applicant portal, we store your personal data in a secure operating environment to protect it from loss or misuse. Your application data will only be made available to persons involved and authorised in the BayWa r.e. application process, e.g. in order to offer you alternative jobs if necessary. Upon the completion of the application process (i.e. after you have received an acceptance or rejection from us), we store your data for a maximum of six months.

9. Communication by email

Please note that transmission of unencrypted emails should be regarded as unsafe, since unauthorised persons may note the content of the email and manipulate it under certain circumstances. Accordingly, we request that you refrain from sending sensitive data by email when communicating with us. As an applicant, please use our applicant portal, since your application documents are transmitted there securely. Should it ever be necessary to send sensitive data by email, please use a content encryption service.

10. What information is collected when you visit this website?

Use of cookies Our website uses what are known as cookies. These are small text files that are stored on your mobile device by the browser. They are harmless. We use cookies to make our website user-friendly. Some cookies remain stored on your device until you delete them and make it easier for us to recognise your browser when you next visit us. If this is against your preference, you can set your browser so that it informs you when cookies are set and only allows this in individual cases. However, deactivating cookies may limit the functionality of our website.

Web analysis The website uses analytical tools to collect general information about the usage behaviour of visitors. This includes, for example, pages accessed, length of stay, referring pages as well as general information about your computer system such as operating system, screen resolution, browser used, etc. All data collected is stored anonymously and cannot be traced back to you personally. If you do not agree to have your usage behaviour recorded anonymously, you can prevent this by deactivating cookies in your browser.

Use of Google Analytics This website also uses Google Analytics, an internet analysis service from Google. Google Analytics uses cookies (small text files) which are stored on your computer and which enable your use of the website to be analysed. The information generated by the cookies about your use of this website (including your IP address) is transmitted to a Google server in the USA and stored there. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties if required by law or if third parties process this data on behalf of Google. Under no circumstances will Google associate your IP address with any other data held by Google. You may reject the use of cookies by configuring the appropriate settings on your browser, but please note that doing so may preclude your access to the full functionality of this website. By using this website, you consent to have data concerning you processed by Google in the manner and for the purposes set out above. We inform you that this website uses Google Analytics exclusively using a deactivation add-on "_anonymizeIp()". Your IP address is not completely stored. Visitors to the website also cannot be identified. By installing the following browser add-on to disable Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=en) you can reject such usage. By doing so, you inform Google Analytics that no information about the website visit should be transmitted to Google Analytics. Without your express consent, we will not use tracking tools surreptitiously for any of the following:

to collect personal data about you,

transfer such data to third parties and marketing platforms, or

link such data with your personal data (name, address, etc.).

As an alternative to the browser Addon or within browsers on mobile phones, you can click this [link] in order to opt-out from being tracked by Google Analytics within this website in the future (the opt-out only applies to the browser in which you set it, and within this domain). An opt-out cookie will be stored on your device, which means that you'll have to click this [link] again, if you delete your cookies.

11. Is any personal data transferred to other countries?

Transfer of data to external countries takes place in individual cases and only on the basis of an adequacy decision of the European Commission, standard contractual clauses, suitable guarantees or your express consent.

12. What data protection rights do I have?

You have a right to information about or the correction, deletion or restriction of the processing of your stored data, a right to object to the processing as well as transfer the relevant data and to file a complaint in accordance with the requirements of data protection law.

Right to information You can request information from us concerning whether and to what extent we process your data.

Right to correction If we process your data in a way that is incomplete or incorrect, you can request that we correct or complete it at any time.

Right to deletion You can request that we delete your data if we process it unlawfully or if the processing interferes disproportionately with your legitimate protection interests. Please note that there may be reasons that prevent immediate deletion, e.g. where legally required storage obligations are imposed. Irrespective of whether or not you exercise your right to deletion, we will delete your data immediately and completely, provided this is unhindered by any legal transaction or legal retention period to the contrary.

Right to limitation of processing You may request that we restrict the processing of your data if:

You dispute the accuracy of the data for a period of time that allows us to verify the accuracy of the data.

The processing of the data is unlawful, but you reject the option of deletion and instead request a restriction on its use,

We no longer need the data for the intended purpose, but you still need this data to assert or defend legal claims, or

You have lodged an objection to the processing of the data.

Right to data portability You may require that we provide you with the data you have given to us in a structured, current and machine-readable format and to allow you to pass this data to another person in charge without our interference, provided that

We process this data on the basis of irrevocable consent granted on your part and or to fulfil a contract between us, and

This processing is carried out using automated methods.

If technically feasible, you can ask that we transfer your data directly to another person responsible.

Right to objection If we process your data for legitimate reasons, you can object to this data processing at any time for reasons arising from your particular situation; this also applies to profiling based on these provisions. We will then refrain from any further processing of your data unless we can prove compelling reasons worth protecting for the processing that outweigh your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims. You can object to the processing of your data for the purpose of direct advertising at any time without giving reasons.

Right of appeal If you believe that we are violating data protection law in the UK when processing your data, please contact us to clarify any questions. Of course, you are also entitled, to contact the supervisory authority responsible for BayWa r.e., the UK Information Commissioner’s Office at www.ico.org.uk.

If you wish to assert any of the above rights against us, please contact the contact named under no. 1. In case of any doubt, we may request additional information to confirm your identity.

13. Am I obliged to provide data?

The processing of your data is necessary to conclude or fulfil your contract with us. If you do not provide us with this information, we will usually have to decline the conclusion of the contract or execution of the order or will no longer be able to execute an existing contract, which will then have to be terminated. However, you are not obliged to give your consent to the processing of data that is not relevant or legally required for the fulfilment of the contract.